Handling of Customers' Personal Information

Created: April 1, 2005

Updated: April 1, 2017

THK RHYTHM AUTOMOTIVE MICHIGAN CORPORATION Managing Director & THK CO., LTD.
CEO
Akihiro Teramachi

Our business is built on our dealings with stakeholders: our customers, of course, but also our shareholders and investors, business partners, and employees.

Managing and protecting the personal information and privacy of our stakeholders is crucial to earning their trust and building long-term positive relationships.

To this end, we have adopted the following basic guidelines for handling personal information and will manage and protect all personal information as stated here.

1. We will abide by all applicable laws and regulations concerning the handling of personal information, make all employees and others involved aware of the importance of protecting personal information, establish rules to ensure correct handling, implement these rules without fail, and continuously improve our processes.

2. We will establish suitable systems for the protection of personal information, taking into account the size and nature of operations in different departments, and handle the collection, use, provision (including provision to subcontractors), disclosure, amendment, suspension of use, and deletion of personal information appropriately and in line with the specified provisions.

3. We will implement safety measures, including information security measures, to ensure the integrity and safety of personal information, and make constant efforts to prevent unauthorized access to or loss, destruction, falsification, leaking, etc. of personal information.

End

Please see below for information regarding the personal information we collect ("Personal Information"): the purpose of use, specific details of how it is handled, and how to contact us with inquiries.

1. Personal Information We Collect

1-1. How we use your information

We only collect Personal Information where necessary to inform our business objectives or where needed to carry out business activities, and this Personal Information is used for the following purposes.

(1) Requests to do business with customers and business partners, internal confirmation of business activities with customers and other associated parties, evaluating and deciding on these business activities, entering into agreements, fulfilling, managing, and terminating agreements, and procedures after contract termination

(2) Providing information about our products and services or those of our group companies

(3) Checks and inquiries for products and services provided to our business partners

(4) Publicizing and confirming attendance for our seminars, exhibitions, etc., or those held by our group companies, communicating with speakers, sending reports to people who attended events or took part in surveys

(5) Confirming visits and entry to our premises

(6) Sending our publications to people who request them, and sending emails to people who sign up to our email service

(7) Asking customers to fill out customer satisfaction surveys

(8) Responding to inquiries or requests from customers and business partners

(9) Exercise of our shareholders' rights and fulfillment of our obligations under company law, as well as implementing various other measures to ensure effective communication with our shareholders, properly identifying our shareholders and promoting mutual understanding including through the creation of standards-compliant data as stipulated by relevant laws and regulations

(10) Communicating with employees of affiliated organizations and providing information that meets their objectives

(11) Communicating our research and development activities to members of research institutions, discussion of matters subject to (1) above under joint development agreements or development contracts, attendance at research meetings, and nomination for academic prizes

(12) Patent applications and management of patent applications with joint applicants

(13) Communicating with journalists, analysts, etc. for PR activities

(14) Receiving job applications when recruiting, communicating with applicants, notifying success/failure of applications, etc.

(15) Communicating with certified public accountants, lawyers, patent attorneys, etc. as required in the course of our business activities

(16) Communicating with group companies for business activities other than the above

(17) Notices to retired employees and other parties

(18) Communicating with the families of our employees

(19) Sharing of information for contracts and as necessary for business activities with subcontractor workers, contract employees, dispatched employees, part-time employees, and temporary employees

(20) Information provision from our company and our group companies incidental to the purposes of use described above

Note: Group companies are companies inside or outside Japan in which we directly or indirectly hold 20% or more of total shareholder voting rights.

1-2. Subcontracting to third parties

To ensure the smooth operation of the business, we may subcontract certain activities to third parties inside or outside Japan and entrust them with the Personal Information required to carry out these activities, only as required for the stated purpose. In such cases, we select the third party only after verifying that they handle Personal Information appropriately, enter into an agreement for handling Personal Information, and ensure that they are appropriately monitored.

1-3. Joint use

We sometimes make joint use of Personal Information together with our group companies, agents, dealerships, and vendors. In such cases, Personal Information subject to joint use will be limited to the individual's name, place of work, home and business addresses, phone number, fax number, and email address, and its use will be limited to providing information on joint products and services and announcements for joint seminars, exhibitions, etc. We are responsible for managing Personal Information subject to joint use.

Note: Agents and dealerships are companies that have entered into agreements with us and are allowed to present themselves as our agents or dealerships, and vendors are companies other than agents or dealerships who are directly authorized by us to sell our products.

1-4. Use for other purposes

If it becomes necessary to use Personal Information for purposes other than those described in "1-1. How we use your information", the individual will be notified or the use will be publicly announced or put in a format readily accessible to the individual, except where the individual has already given permission or where required by law. Changes to how we use Personal Information will only be made to the extent that there is reasonably acknowledged to be a connection with the previous purposes.

1-5. Provision of personal information to third parties

We will not provide Personal Information to third parties except in the following circumstances.

(1) Where the individual has consented

(2) When sharing statistical or other data that does not contain information that is personally identifiable

(3) When providing Personal Information to subcontracted third parties when subcontracting certain business activities to third parties, to the extent required to carry out the business activities, and only as required for the stated purpose (see 1-2. "Subcontracting to third parties")

(4) When using Personal Information jointly with group companies, agents, dealerships or vendors, only as required for the stated purpose (see 1-3. "Joint use")

(5) As required by law

(6) Where it is difficult to get permission from the individual, but providing the information is necessary to preserve life, ensure personal safety or protect property

(7) Where it is difficult to get permission from the individual, but providing the information is essential to improving public health or promoting sound child development

(8) Where required to assist national agencies, regional public bodies or their representatives in the course of carrying out their duties as defined by law, and where obtaining permission from the individual might obstruct said duties

2. Procedures for Disclosure, Amendment, Suspension of Use, Deletion, etc. of Personal Information

2-1. Requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information

Please use the specified form for requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information (download the form from the following link and print out to use: [Link]), fill in the required fields, attach one piece of personal identification (copy of official document such as driving license or passport) for the individual concerned ("Personal ID"), and send it to the address below together with return postage. Writing "Enc. request for disclosure" in red on the envelope will help us expedite your request.

Alternatively, if information was registered through our site by our technical support or email newsletter staff, requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information can be made as specified on the site, subject to our ability to properly confirm that the requester is the individual concerned.

THK RHYTHM AUTOMOTIVE GmbH
European Headquarters
Fichtenstraße 37, 40233 Duesseldorf Germany
Phone: +49-211-90955-0
Email: info@trde.thk.com

2-2. Requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information made by a representative

Anyone requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information must be a legal representative of the individual concerned, or if charged with requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information by the individual concerned and acting as their representative, must enclose Personal ID with the request along with the other documents listed below.

(1) If a legal representative (both documents listed below are required.)

・One document proving status as a legal representative (for minors, copy of entire Japanese family register (copy of health insurance document showing the individual concerned is a dependent is acceptable if the representative has parental authority), or for adult wards, a copy of document proving registered details)

・One document proving the identity of the legal representative (copy of official document such as driving license or passport belonging to the legal representative)

(2) If appointed to represent the individual (both documents listed below are required.)

・When requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information, one document proving that the individual concerned has delegated the request, stamped with their registered seal (letter of attorney or equivalent)

・One seal registration certificate for the individual concerned

2-3. Fees for requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information

There is no charge for these requests. However, the requester is responsible for postage (including return postage).

2-4. Response to requests for disclosure, amendment, suspension of use, deletion, etc. of Personal Information

We will reply by post to the address given by the requester on the request form.

2-5. Reasons for not disclosing retained Personal Information

We will not disclose personal information in the following cases. If we decide not to disclose information, we will communicate that decision along with the reason why.

(1) Where the individual cannot be positively identified, for example if the address on the request form or the Personal ID does not match the address we hold

(2) Where authority as a representative cannot be verified in the case of a request from a representative

(3) Where there is insufficient information, for example omissions in the specified request form

(4) Where we do not hold the Personal Information subject to a request for disclosure, etc.

(5) Where doing so might involve a risk to the life, personal safety, property, or other right or benefit of the individual concerned or a third party

(6) Where doing so might seriously obstruct the appropriate performance of our business activities

(7) Where doing so would violate other laws or regulations

3. Contact for Questions About Personal Information

If you have any questions about our personal information protection policy or how we protect personal information, suggestions for improvements to our safeguarding of personal information, or if you want to talk to someone about requesting disclosure, amendment, suspension of use, deletion, etc. of Personal Information, please contact our personal information handling service at the contact details given below. Please note that we cannot accept requests in person at our offices.

THK RHYTHM AUTOMOTIVE GmbH
European Headquarters
Fichtenstraße 37, 40233 Duesseldorf Germany
Phone: +49-211-90955-0
Email: info@trde.thk.com

4. Use of Personal Information on Our Site

(1) Information we collect

We do not collect any personally identifying information (name, address, phone number, email address, etc.) from visitors to our site without their consent. We may, however, collect data other than Personal Information. Examples of the type of data we collect are which pages visitors viewed, and the domain names of sites from which visitors access our site. This data is used to improve our site.

(2) Cookies

Some pages on our site use cookies. Using cookies allows us to identify a user's computer, but does not identify or collect any Personal Information. Users can disable cookies by changing their browser settings, but this may prevent use of some or all functionality on web pages.

(3) Google Analytics

We use the Google Analytics service from Google, Inc. ("Google") on some pages on our site to understand how visitors use our site. Using Google Analytics on our site means that Google collects, records, and analyzes the browsing history of visitors to our site based on the cookies we issue. We receive the results of the analysis from Google and use it to understand how users visit our site. No data about users collected, recorded, or analyzed by Google Analytics contains personally identifying information. This data is also managed by Google in accordance with their privacy policy.
Users can disable Google Analytics in browser add-on settings, preventing Google Analytics from collecting their data. Google Analytics can be disabled by downloading the "Google Analytics Opt-out Browser Add-on" from the Google opt-out browser add-on download page, installing the add-on, and configuring the browser add-on settings. If a user disables Google Analytics, it will disable Google Analytics on all sites and not just ours, but it can be re-enabled at any time by changing browser add-on settings.

Please see the Google Analytics site for an explanation of the Google Analytics Terms of Service, and the Google site for an explanation of their Privacy Policy.

Google Analytics Terms of Service:
www.google.com/analytics/terms/us.html
Google Privacy Policy:
www.google.com/intl/en/policies/privacy/
Google Analytics Opt-out Add-on:
tools.google.com/dlpage/gaoptout?hl=enw

Note: "Google Analytics" is a registered trademark of Google.

(4) Other

We have no liability or responsibility for the protection of Personal Information on websites that are linked from our site. Please direct any questions or inquiries about the handling of Personal Information on other websites directly to the site owners.

If you have any questions about this statement, please contact us using our Contact Form.

 
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